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Re: Objections to JTC-1 Fast-Track Processing of the ECMA-376 Specification

To whom it may concern,

I, Gareth Eason, write on behalf of the committee and members of the Irish Linux User Group to voice our collective concern regarding the Fast-Track Processing of the ECMA 376 Specification by the ISO JTC-1 committee.

As more and more of our critical paperwork gets stored in electronic form, the ISO body recognise the requirement for an open standard for storing this data — one with which multiple software vendors may comply. This avoids a monopoly situation emerging whereby a single supplier may control access to information simply because only they can understand the format it is stored in. This is particularly true for legacy documents — old documents produced and 'saved' by an older version of software.

As a predominantly technical body of people within Ireland, we feel it important to highlight our concerns to the fast-track processing of this proposed standard for the following reasons:

* The ECMA specification runs to some 6,000 pages, impossible to review in any meaningful fashion within the 30 days permitted.
* The concept of the standard potentially conflicts with the ISO body's own stated goal of "one standard, one test, and one conformity assessment procedure accepted everywhere." ECMA has been publicly slated as an alternative to an already existing and ratified open document standard, ISO/IEC 26300:2006.
* There appears to be internal inconsistencies within the proposed standard and significant conflicts with existing ratified ISO standards, including ISO8601 (Representation of Dates and Times), ISO639 (Codes for the representation of Names and Languages), ISO/IEC 8632 (Computer Graphics Metafiles) and more.
* There are numerous references to proprietary applications and behaviours which may be impossible to reproduce without potentially infringing patents granted to, in particular, Microsoft. No documentation as to proprietary behaviours is offered in many cases and no legal indemnification appears to be granted for either reverse engineering or re-implementation of these behaviours. This renders it legally and technically impossible for any organisation other that Microsoft to implement this standard, essentially prohibiting competition — the antithesis of ISO standards.

We would suggest that it is inappropriate to fast-track the processing of this proposed ECMA 376 standard and that it should be diverted from its present fast-track processing and should be remanded to Ecma International for: (i) harmonization with ISO/IEC 26300:2006, the OpenDocument standard; and numerous other standards that it contradicts; (ii) development of more suitable intellectual property documents that actually grant rights to implement the specification.